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| Section | Weight | Objectives |
|---|---|---|
| Topic 1: Governance and Enforcement | 25% | - Compliance obligations and governance structures - Enforcement mechanisms and penalties - International sanctions frameworks - Regulatory bodies and authorities |
| Topic 2: Sanctions Due Diligence | 20% | - Enhanced due diligence for high-risk scenarios - Customer and counterparty due diligence requirements - Risk assessment and categorization - Ongoing monitoring and record keeping |
| Topic 3: Sanctions Evasion Techniques | 17.5% | - Digital and emerging risks in evasion - Common evasion methods and typologies - Trade-based money laundering and sanctions circumvention - Use of intermediaries, shell companies and complex structures |
| Topic 4: Sanctions Screening | 20% | - Screening methodologies and tools - Transaction and relationship screening - Sanctions lists and designated parties - Matching logic, false positives and resolution |
| Topic 5: Sanctions Investigations and Asset Freezing | 17.5% | - Asset freezing, seizure and restriction measures - Reporting obligations to authorities - Investigation protocols and procedures - Disposition of frozen assets |
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NEW QUESTION # 54
Which should be considered when selecting the appropriate watch lists to screen the customer base?
Answer: B
Explanation:
Selecting watch lists for sanctions screening requires understanding geographic exposure, including customer locations, jurisdictions in which products/services are offered, and locations of trading partners. Sanctions programs vary by region (e.g., OFAC, EU, UN, UK), so geographic impact is essential.
Transaction size, withdrawal patterns, and relationship length are AML considerations but are not primary factors for selecting sanctions watch lists.
Reference:
Risk-based approach to sanctions list selection.
Consideration of geographic exposure to sanctioned jurisdictions.
NEW QUESTION # 55
A compliance analyst at a UK-based company is reviewing a transaction alert for Entity A. A representative provided documentation that a UK Asset Freeze individual reduced their stake in Entity A from 70% to 30% shortly after they became subject to sanctions. Which steps should the analyst recommend first?
Answer: D
Explanation:
Under UK OFSI rules, entities owned or controlled by a designated person remain subject to asset freeze restrictions. A reduction in ownership from above 50% to below 50%, particularly when occurring immediately after designation, requires enhanced due diligence to determine whether the divestment is genuine or merely an attempt to evade sanctions.
Sanctions and Compliance Domains emphasize the need for verification when documentation claims ownership reduction. Institutions must confirm authenticity, timing, beneficiaries of the transfer, and any continuing control influence by the designated person.
Approving the transaction before verification, removing screening, or rejecting without confirming details contradicts UK sanctions compliance expectations. Enhanced due diligence is the required first step.
Reference from Sanctions and Compliance Domains:
OFSI ownership and control criteria, including obligations when ownership reductions occur post-designation.
Requirements for enhanced due diligence to confirm legitimacy of divestment or restructuring.
Risk indicators of sanctions evasion through rapid ownership structure changes.
NEW QUESTION # 56
A community correctional center to which an offender reports each day to file a daily schedule with a supervision officer, showing how each hour will be spent is called which of the following?
Answer: C
NEW QUESTION # 57
Which exogenous events sporadically derailed the changes in general of punishing Cuba?
Answer: C,D
NEW QUESTION # 58
Which of the following questions is/are to be asked while identifying causes in building a casual model?
Answer: A,C,D
NEW QUESTION # 59
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